Privacy policy
05/23/2024
PRIVACY POLICY
1.Table of Contents
GENERAL INFORMATION
1.1.2 Data Protection Officer 4
2. DEFINITIONS 4
PROCESSING OF PERSONAL INFORMATION 5
3.1 Collection of Personal Information 5
3.2 Use of Personal Information 7
3.3 Disclosure of Personal Information 8
3.3.2 Compliance with Laws, Legal Requests, Damage Prevention, and Protection of Our Rights 9
3.3.3 Business Transaction 9
3.3.4 Consent for Personal Information 9
3.3.5 Retention of Personal Information 9
3.3.6 Sensitive Personal Information 10
4. YOUR RIGHTS 10
5. COOKIES AND OTHER TRACKING TECHNOLOGIES 11
6. SECURITY MEASURES 12
7. UPDATES TO OUR PRIVACY POLICY 12
8. LINKS TO THIRD-PARTY WEBSITES 13
9. LIMITATION OF LIABILITY 13
10. MINORS UNDER THE AGE OF 14 13
11. USER-GENERATED CONTENT 14
12. CONTACT US 14
1.General Information
1.1 Introduction
Privacy protection is important to Tout-Louer Inc. (hereinafter referred to as "The Organization", "we", "our"). For this reason, we have implemented protective measures and good management practices for your personal information in accordance with applicable laws, notably Law 25.
This privacy policy (the "Policy"), which should be read in conjunction with the website's terms of use and the Service agreements entered into with the Organization, describes our practices regarding the collection, use, processing, disclosure, and retention of our clients', visitors', and users' Personal Information.
By using our website www.tout-louer.com (the "Website") or transacting with us, you agree that we may collect, use, process, disclose, and retain your Personal Information in accordance with the terms described herein. If you do not agree to comply with and be bound by this Policy, you are not authorized to visit, access, or use our Website, nor to share your Personal Information with us.
This Policy does not apply to the Personal Information of employees, representatives, and consultants of the Organization, or any other person affiliated with the Organization, nor to any information that does not constitute personal information as defined by applicable law.
1.2 Data Protection Officer (DPO)
Questions, comments, and complaints regarding the Policy and the Organization's privacy practices can be addressed to our Data Protection Officer at the following contact details:
Email: contact@tout-louer.com
Address: 405 rue Notre dame E, Y2Y 1C9 Montreal (Quebec), Canada
2.Definitions
The following words and expressions, when capitalized in this Policy, have the meanings attributed to them below, unless explicitly or implicitly indicated otherwise in the text:
"Service Provider": Any individual or legal entity that processes data on behalf of the Organization. This includes third-party organizations or individuals employed by the Organization to facilitate the Services, provide Services on behalf of the Organization, perform Services related to the Services, or assist the Organization in analyzing the use of the Services.
"Personal Information": Any information that relates to an individual and allows them to be identified directly or indirectly, meaning that it reveals directly or indirectly, or by reference, something about the identity, characteristics, activities, location, or other identifiable information of that person, regardless of the nature of the medium and the form in which this information is accessible (written, graphic, sound, visual, computerized, or otherwise). This always includes sensitive personal information.
"Sensitive Personal Information": Personal information that, by its nature or due to the context of its use or disclosure, evokes a high degree of reasonable expectation of protection from the person concerned. (For example, medical, biometric, genetic, or financial information, or information about sexual life or orientation, religious or philosophical beliefs, union membership, or ethnic origin.)
"Data Protection Officer": The person designated to ensure privacy protection within the Organization (DPO).
"Services": Refers to the Website and all related services offered by the Organization, which include professional services and, where applicable, associated media, printed materials, and "online" or electronic documentation.
3.Processing of Personal Information
This is a reformulated version of your Privacy Policy in English. The structure and specific details have been kept intact to ensure accuracy and compliance with the original document.
3.1 Collection of Personal Information
Your Implied Consent to Share Your Personal Information with Us
Respecting your privacy and maintaining the confidentiality of your data is paramount to the Organization. This Privacy Policy outlines which personal information we collect through technological means, the purposes for which it is collected, the methods used for collection, how we process it, and when we need to disclose it to subcontractors or third parties. It also covers the privacy and security measures in place as well as your rights regarding your personal information.
By providing us with your personal information, you authorize the Organization to collect and process your personal information necessary to offer you our services. Please note that you retain control over your personal information at all times and can refuse to allow us to collect personal information about you. To do so, simply inform us or mention it when the information is being collected on paper, verbally, or in the presence of one of our staff members. You can also inquire with our Customer Service or our Data Protection Officer (DPO) about the information collected through electronic means and indicate your refusal for the collection. It is possible that we may not be able to serve you if you refuse.
The consent you give us at the time of collection or processing of your personal information can be withdrawn at any time. We ensure that your choice is respected in accordance with our legal obligations.
In our activities, we collect and use personal information through specified collection methods such as:
●Browsing our website;
●Downloading our applications on your smart electronic devices;
●Communicating with us via phone or live chat;
●Interacting on social media;
Interacting on websites such as Facebook, YouTube, etc.;
●Viewing or interacting with our online advertisements;
●Interacting with our authorized representatives;
●Audio or video recordings.
Specifically, we collect the following personal information:
Via our website and all electronic means:
●Contact details such as your first and last name, email address, mailing address, phone number, gender, date of birth, credit card number, and geolocation to complete the website registration form and our white paper form;
●Contact details such as your first and last name, billing address, shipping address, and company name when you create a customer account with us;
●Information automatically collected during the use of the website and our services, including:
●Connection information and other information about your activities on the website, such as the pages you visited and the queries you made;
●Credit card or other payment method information, and other related information for any transactional section on our website.
Personal information may also be captured by our Internet payment partners, whose servers may be located outside the province of Quebec. To learn more about their processing, retention, and destruction methods, please refer to our partners' privacy policies.
During your interactions with us:
●Professional or employment-related information, such as your resume, place of employment, previous titles or positions, employers, owned businesses, salary or self-employment income, criminal background information, and other information you provide when applying for a job within our Organization;
●Contact details such as your first and last name, email address, phone number, address, and business number for creating a customer account;
●Tax information, including your income and other personal financial information;
●Information about products or services, such as details of the services we have provided to you;
●Transaction and payment information, such as the payment method used, date and time, payment amount, billing postal code, address, and other related information;
●Information you choose to provide or transmit to us, for example, when filling out a form, responding to surveys, or communicating with one of our employees or representatives.
In each case, this personal information is processed in accordance with the legitimate and necessary purposes listed in Section 3.2 below. Additionally, we ensure that we collect and process only the data and personal information strictly necessary for the purposes for which you provide it. If secondary use of your personal information is required, we will notify you and obtain your consent as required by law.
3.2 Use of Personal Information
As indicated in section 3.1, we use your personal information only within the limits authorized by law. We may use your personal information for the legitimate purposes described below:
●Providing you with services;
●Allowing you to subscribe to our newsletter;
●Verifying your identity and reviewing your personal background as permitted by law;
●Operating, maintaining, monitoring, developing, improving, and offering all functionalities of our website;
●Managing risk and activities;
●Complying with our obligations under applicable laws and regulations;
●Developing new services and improving our website and services;
●For marketing and business development purposes, if you have previously consented to the processing of your personal information for these purposes;
●Sending you messages, updates, and security alerts;
●Responding to your questions and providing assistance as needed;
●Administering a contest, promotion, survey, or other website or service feature;
Collecting feedback and comments regarding our services;
●Conducting research and analysis related to our business and services;
●Detecting and preventing fraud, errors, spam, abuse, security incidents, and other harmful activities;
●Asserting, exercising, or defending a right or legal proceeding;
●Sending you communications as permitted by law;
●Allowing the function to apply for a job with the Organization;
●For any other purpose permitted or required by law.
We will seek your consent before using or disclosing your personal information for purposes other than those stated herein.
Please note that we do not use the information we collect to make any inferences or interpretations.
The personal information we collect and retain is securely stored on servers located in Beauharnois (BHS), Canada. Rest assured that this personal information is disclosed only when we have a legal obligation to do so.
3.3 Disclosure of Personal Information
We may disclose your Personal Information to our employees, contractors, consultants, agents, Service Providers, and other trusted third parties who require this information to assist us in operating our Website, conducting and protecting our business activities, or serving you, provided that these Service Providers have previously agreed in writing to maintain the confidentiality of your Personal Information in accordance with applicable laws and our Information Governance Program. Additionally, only members of our Organization's staff who need to access and process your personal information will have access, in compliance with our Internal Policy on the Protection of Personal Information.
We do not sell, trade, or otherwise disclose your personal information to third parties, except as permitted by law.
3.3.1 Service Providers and Other Third Parties
Although we strive to avoid disclosing your Personal Information to third parties, we may engage Service Providers to perform various services on our behalf, such as IT management and security, marketing, data analysis, hosting, and storage. Below are the instances in which such sharing may occur:
- We use cloud data hosting services. The servers are located in Quebec.
- We use a third-party provider to manage our customer relationships.
When we disclose your Personal Information to Service Providers, we ensure that the principles outlined in this Policy are adhered to, and these Service Providers are required to use the Personal Information according to our instructions and solely for the purposes for which it was provided. Additionally, these Service Providers provide us with sufficient guarantees regarding the implementation of appropriate protective measures that are proportionate to the sensitivity of the personal information processed or disclosed. When our Service Providers no longer need your personal information, they must properly destroy the data.
3.3.2 Compliance with Legislation, Response to Legal Requests, Prevention of Harm, and Protection of Our Rights
We may disclose your Personal Information when we believe such disclosure is authorized, necessary, or appropriate, including:
- ●To respond to requests from public and governmental authorities, including public and governmental authorities outside your country of residence;
- ●To protect our operations;
- ●To comply with legal processes;
- ●To protect our rights, privacy, safety, property, and those of you or third parties;
- ●To enable us to pursue available remedies or limit the damages we may sustain; and
- ●In accordance with applicable laws, including laws outside your country of residence.
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3.3.3 Business Transaction
We may share, transfer, or disclose your Personal Information, in strict accordance with this Policy, in the event of a sale, transfer, or assignment of all or part of our Organization or its assets (e.g., as a result of a merger, consolidation, change of control, reorganization, bankruptcy, liquidation, or any other business transaction, including during the negotiation of such transactions). In such a case, if the transaction is finalized, we will notify you before your Personal Information is transferred and becomes subject to a different privacy policy. If the transaction is not finalized, the prospective buyer will be required to destroy any Personal Information we have shared with them for the purposes of the transaction.
3.3.4 Consent from the Individual Concerned with Personal Information
Whenever possible, the Organization directly obtains consent from the individual concerned for the collection, use, and disclosure of their Personal Information. However, if you provide us with Personal Information about other individuals, you must ensure that you have properly informed them that you are providing their information to us and have obtained their consent for such disclosure.
3.3.5 Retention of Personal Information
Subject to applicable laws, we retain your Personal Information only for the time necessary to fulfill the purposes for which it was collected, unless you consent to the use or processing of your Personal Information for another purpose. Additionally, our retention periods may be adjusted as needed for legitimate interests (e.g., to ensure the security of Personal Information, to prevent misuse and breaches, or to pursue offenders).
Rest assured that once the purpose for which the information was collected has been fulfilled, we will proceed to destroy or anonymize the information in accordance with applicable legislation.
For more information on the periods during which your Personal Information is retained, please contact our Privacy Officer using the contact details provided in Section 1.2 of this Policy.
3.4 Sensitive Personal Information
In the course of our activities, we collect Personal Information considered sensitive when it is strictly necessary for our operations. In such cases, we ensure that we have your explicit consent to do so, in accordance with the Law.
4. Your Rights
You can exercise the rights listed below by completing the form available [here] and submitting it via secure email or by mail to the attention of our Privacy Officer using the contact details provided in Section 1.2 of the Policy:
- ●You have the right to access the Personal Information we hold about you and to request a paper copy of documents containing your Personal Information, subject to the exceptions provided by applicable law;
- ●You have the right to have the Personal Information we hold about you rectified, modified, and updated if it is incomplete, ambiguous, outdated, or inaccurate;
- ●You have the right to withdraw or modify your consent to the Organization's collection, use, disclosure, or retention of your Personal Information at any time, subject to applicable legal and contractual restrictions;
- ●You have the right to request that we stop disseminating your Personal Information and to de-index any link attached to your name that provides access to this information if such dissemination violates the law or a court order; and
- ●You have the right to file a complaint with the Commission d’accès à l’information, subject to the conditions provided by applicable law.
To process your request, you may be required to provide appropriate identification or otherwise verify your identity.
We encourage all our clients to keep their Personal Information with us up to date. Decisions regarding the various services we offer to our clients may vary based on the accuracy of this data. Therefore, it is essential to ensure we have an accurate picture of your situation.
1. Cookies and Other Tracking Technologies
We use cookies and similar technologies (collectively, "Cookies") to help operate, protect, and optimize the Website and the services we offer. Cookies are small text files stored on your device or browser. While some of the Cookies we use are deleted after your browser session ends, other Cookies remain on your device or browser to allow us to recognize your browser during your next visit to the Website. The data collected through these Cookies is not intended to identify you personally. They primarily ensure the Website's functionality, enhance the user browsing experience, and provide data that helps us better understand traffic and interactions on our Website, as well as detect certain types of fraud. Cookies do not cause any harm to your device and cannot be used to extract your personal information.
Among the Cookies we collect through our Website are the following:
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●Functional Cookies: These cookies allow the Website to remember the choices you make (such as your username, preferred language, etc.) to provide a personalized and enhanced experience during your future visits. This includes cookies for automatic login and easier login processes.
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●Analytical Cookies: These cookies help us analyze and understand how you use our Website, to improve its usability, features, and content. This includes cookies related to Google Analytics for website usage analysis and other cookies for tracking usage statistics of our website.
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●Advertising Cookies: These cookies are used to display relevant advertisements based on your interests and browsing history.
You can configure your browser to notify you when Cookies are being set during your visit to the Website, so you can decide whether to accept or reject some or all Cookies. Please note that disabling Cookies on your browser may affect your browsing experience on the Website and prevent you from using certain features.
5. Email Tracking
We may use email tracking technologies such as pixel tags or web beacons in our emails to collect information such as the time and date of email opening, recipient's location and IP address, and links clicked. This data is used to analyze the performance of email campaigns and to improve the content and relevance of future email communications. To opt out of email tracking, you can disable HTML or images in your email client. Please note that this action may also disable images in the email and result in incomplete display of email content. You can also choose to unsubscribe from our marketing and promotional emails.
2. Security Measures
The Organization has implemented physical, technological, and organizational security measures to adequately protect the confidentiality and security of your personal information against loss, theft, unauthorized access, disclosure, copying, use, or modification.
Among the various measures implemented:
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Our Website employs Secure Sockets Layer (SSL) protocol, network monitoring software, firewalls, and other tools that ensure a secure connection between your device and our server.
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Organization employees are familiar with this Policy and have committed to adhering to it, respecting the confidentiality of personal information regarding our potential and existing clients. Additionally, each employee pledges to follow and uphold a data governance policy applicable to all Organization personnel; we regularly train and raise awareness among our staff on the application of these policies in their daily activities.
- As mentioned in section 3.3, we have implemented access controls for personal information that limit access only to individuals with a valid reason to view, process, disclose, or otherwise use your information.
- As mentioned in section 3.3, subcontractors and third parties who do business with the Organization and with whom we sometimes need to share your personal information have previously committed to protecting the confidentiality and privacy of this information.
- Once the purpose for which your personal information was collected is fulfilled and we no longer need to retain it, the Organization securely destroys or anonymizes this data, subject to applicable laws. The measures we use are appropriate to the information we collect.
Despite the measures described above, we cannot guarantee the absolute security of your personal information. We encourage you to exercise caution when browsing our Website. Access to your account is enabled through a password of your choosing. It is important not to disclose it or reuse a password used on other sites. If you have reason to believe that your personal information is no longer secure, please contact our Privacy Officer immediately using the contact details provided in Section 1.2 above.
3. Modification of this Privacy Policy
We reserve the right to modify this Policy at any time in accordance with applicable law. In the event of a modification, we will publish the revised version of the Privacy Policy and update the revision date in the footer of the Policy. If you do not agree with the new terms of the Privacy Policy, we invite you to discontinue using our Website and Services. If you choose to continue using our Website or Services after the effective date of the new version of our Policy, your use of our Website and Services will be governed by this new version of the Policy.
4. Links to Third-Party Websites
Occasionally, we may include references or links on our Website to websites, products, or services provided by third parties ("Third-Party Services"). These Third-Party Services, which are not operated or controlled by the Organization, are governed by privacy policies that are entirely separate and independent from ours. Therefore, we assume no responsibility for the content and activities of these sites. This Policy applies solely to the Website and services we offer. This Policy does not extend to Third-Party Services.
5. Limitation of Liability
The Organization is committed to taking all reasonable measures to ensure a level of confidentiality and security of Personal Information consistent with appropriate technological standards for its sector of activity.
However, notwithstanding the above, you acknowledge and understand that no computer system provides absolute security, and there is always some risk involved when transmitting personal information over the public internet.
You agree that the Organization cannot be held liable for any breach of confidentiality, hacking, viruses, loss, theft, misuse, or alteration of Personal Information transmitted or hosted on its systems or those of a third party. You also waive any claims in this regard, except in cases of gross negligence or intentional misconduct by the Organization. Accordingly, you agree to release the Organization and its officers, directors, affiliates, and business partners from any liability for any damages of any kind, whether direct or indirect, incidental, special, or consequential, arising from the use of your Personal Information.
In the event of a breach of confidentiality or security of your Personal Information posing a high risk to your rights and freedoms, you will be notified as soon as possible, and the Organization will take necessary steps to preserve the confidentiality and security of your Personal Information.
6. Individuals Under the Age of 14
We do not knowingly collect or use Personal Information from individuals under the age of 14. If you are under 14 years old, you should not provide us with your Personal Information without the consent of your parent or guardian. If you are a parent or guardian and become aware that your child has provided us with Personal Information without your consent, please contact us using the contact details provided in Section 1.2 above to request that we delete the child's Personal Information from our systems.
7. User-Generated Content
Users of the Website have the option, through their user account, to post comments and other information as they desire. Please be reminded that the Organization cannot be held responsible for the content of your comments, nor for any consequences that may arise from them. We strongly advise against posting any Personal Information about yourself on our Website to ensure the protection of your personal data.
8. Contact Us
Any questions, comments, requests, or concerns regarding this privacy policy should be addressed to our Privacy Officer at the contact information provided in Section 1.2 of this policy.